Mobis India aims compliance management as a management philosophy which is essential for ethical and sustainable management of the company, and has created a Code of Conduct to establish a supply chain as a part of it. The Code of Conduct complies with all laws and regulations (including but not limited to all the relevant corruption, economic sanctions, forced labor, safety/health and fair trade acts) applied to the business activities of internal and external Mobis India suppliers/ service providers/ business partners (Hereafter "Mobis India Business Partners") that signed a contract to supply goods and services or concluded other contracts with Mobis India, and it calls for the best operational practice in ethics, environment, labor/human rights, safety/health, and management system areas. Mobis India looks forward to being more respected company from the society and seize an opportunity of mutual growth as all the supply chains including Mobis India business partners comply with the Code of Conduct.
The Code of Conduct has been established based on the Global Automotive Sustainability Practical Guidance of Drive Sustainability and referred to the Code of Conduct of the Responsible Business Alliance. Moreover, the latest global trends have been applied such as ESG-related guidelines, laws and regulations relating to supply chain for human rights and environment including the EU Directive for Sustainability Due Diligence. If recommendations and requirements in the Code of Conduct are contradictory to laws and regulations of the applicable country, the laws and regulations have precedence over the Code of Conduct, and it may be changed depending on the course and trend of Indian laws.
C. Roles and Responsibilities of Business Partners
Mobis India business partners shall consider suggestions from the Code of Conduct when they make a managerial decision-making and operate their business. Mobis India and third-party agencies commissioned by Mobis India may conduct a due diligence on Mobis India business partners to inspect their compliance. Mobis India may have the right to recommend improvements on identified risks as a result of the inspection, and Mobis India business partners will formulate and perform a risk handling plan after mutual discussion. Compliance with this Code of Conduct may serve as a critical criterion for the selection of Mobis India business partners. If a business partner violates this Code and fails to make appropriate improvement efforts, it may become subject to review by the Mobis India Partner Sanction Committee and may face sanctions in accordance with the applicable sanction regulations.
The Code of Conduct does not state all the obligations that Mobis India business partners should implement, and may be regularly supplemented and revised to establish a sustainable supply chain. The Code of Conduct is available on the website of Mobis India and for more information, it is possible to inquire to the relevant department. Furthermore, Mobis India will support members of Mobis India business partners that they can fully understand the Code of Conduct as we provide accessible, optimal channels (voice, image, written, etc.) and types (Korean, English version) of it, and help the partners deliver the purpose of the Code of Conduct to their suppliers (sub-suppliers).
2. Ethics
A. Transparent Management and Anti-corruption
①
Employees of Mobis India business partners shall comply with all the relevant laws and regulations and maintain a high level of integrity in each country where they carry on their businesses.
②
Employees of Mobis India business partners shall not pull rank their positions to consent to bribery, threaten, embezzle, aid and abet, ask for favors, and do money laundering including unreasonable demand by finding faults.
③
Mobis India business partners shall prepare internal procedures that manage suspicious transactions, and strive to protect whistleblowers against unfair measures on grounds of report.
④
Mobis India business partners shall not make unreasonable demands on recruitment fee or commission to workers in each workplace.
B. Prevention of Conflict of Interest
① A conflict of interest refers to any situation where an employee’s personal interests, such as financial or family-related, or other private relationships, interfere with or appear to interfere with, objective and fair judgement in pursuing the company’s interests and fulfilling social responsibilities. This includes activities, relationships and investments that may compromise the objectivity of an employee's decisions or their duty of loyalty to the company.
② Mobis India business partners shall perform their business with sense of responsibility according to respective
operational rules.
③ Employees of Mobis India business partners shall not promise, propose, approve, offer a bribe to another person with
the intent of obtaining inappropriate benefits. In this regard, any acts of being offered benefits personally from a third
party or being caused damage to the company are also unacceptable.
C. Protection from Unfair Trading
①
Mobis India business partners shall comply with fair trade laws/regulations and standards of each country where they carry on their business.
②
Mobis India business partners shall not hinder fair competition through unfair transactions such as abuse of market dominant positions or superior positions.
③
Mobis India business partners shall pay to sub-suppliers on a settlement day in the transaction contract, and not make adjustment by the reduction of amount discretionally.
④
Mobis India business partners shall not agree to actions that unfairly set limits to competitions over price, supplies, and trading areas/conditions of products or services with other business operators.
⑤
Mobis India business partners do not obtain information by unlawful means from competitors, suppliers (sub-supplier) or other agencies, and shall not disclose information that a company or a third party acquires fraudulently.
D. Prevention of Counterfeit Parts
①
Mobis India business partners shall not produce or use unapproved raw materials and parts, and not consume or sell counterfeit raw materials and parts.
②
Mobis India business partners shall verify that counterfeit raw materials and parts are used or manufactured in their workplace regularly and when confirmed the fact that illicit use of them, it shall be immediately notified to the government or client companies.
③
Mobis India business partners shall strive to verify that produced raw materials and parts are used and distributed according to the terms of contract or its business purpose.
E. Compliance of Restriction on Exports and Economic Sanctions
①
Mobis India business partners shall comply with international laws and regulations relating to restriction on exports and economic sanctions by each country. ②
Mobis India business partners shall not trade with countries, regions, corporations, groups, and individuals which are applied restriction on exports and economic sanctions.
③
Mobis India business partners shall inspect that they follow laws and regulations relating to restriction on exports and economic sanctions, and cooperate to grasp the current situation of Mobis India if necessary.
F. Protection of Information
①
Mobis India business partners do not release trade secrets or information requiring security of client companies and suppliers (sub-suppliers), and shall not archive information acquired from work without prior permission/approval. ① Mobis India business partners shall comply with environmental laws and regulations of each country where they run
their business, and obtain/maintain all environmental licenses requiring for the business.
② Mobis India business partners shall strive to improve energy efficiency while minimizing and reducing energy
consumption and greenhouse gas emissions
③ Mobis India business partners shall track and document annual consumption and usage for greenhouse gas emission
sources under Scope 15, Scope 2 and Category 1 of Scope 36, and disclose annual emissions in line with reduction
targets.
C. Management of Water Resources
①
Mobis India business partners shall measure amount of water used/waste water discharge, and discharge concentration of water pollutants and build a monitoring system that operates control facilities properly. ②
Mobis India business partners shall exert an effort to decrease amount of water resources and increase amount of recycling. Moreover, water pollutants shall be managed according to legal standards or stricter internal standards.
③ Mobis India business partners shall establish appropriate and effective procedures to prevent stormwater contamination and to ensure contaminated stormwater and chemicals do not enter storm drains.
D. Management of Air Pollutants
①
Mobis India business partners shall measure air pollutant emissions and its concentration, and construct a monitoring system that operates prevention facilities for appropriate treatment. ②
Mobis India business partners shall minimize air pollutant emissions in proper means. Furthermore, air pollutants shall be managed according to legal standards or stricter internal standards.
E. Ozone- depleting Substance (ODS) Management
① Mobis India business partners shall regularly inspect and document the status of ODS ownership and use, prohibit any new ODS use, and prioritize the adoption of alternative materials and technologies ② If the use of such substances is inevitable, Mobis India business partners shall conduct a risk assessment to review potential impacts on human health and the environment and establish measures for reduction and management.
③ Mobis India business partners shall set goals for reducing ODS usage and phasing in alternatives, monitor and improve progress and share this data transparently upon the company’s request.
F. Management of Resource Circulation and Waste
①
Mobis India business partners shall establish a system that measures, stores, and discharges waste properly. ②
Mobis India business partners shall minimize the disposal of waste to be landfilled and incinerated in proper means. As a part of it, there shall be efforts to expand use of waste/recycling and recover discarded raw materials and parts.
③
Mobis India business partners shall make efforts to minimize residues that might affect environment by considering total life cycle of products when landfilling or incinerating waste.
G. Management of Chemicals
①
Mobis India business partners shall manage transportation, storage, use, and disposal of chemicals safely throughout the whole process of business. There shall be a label that identifies risk and harmfulness on the handled chemicals or information containing the above shall be disclosed. ② Mobis India business partners shall implement effective programs that comply with legal and customer requirements regarding the regulations of hazardous chemicals contained in products. These programs shall include useful procedures for measuring, analyzing and documenting the chemical composition of products.
H. Noise Management
① Mobis India business partners shall ensure that workplace noise levels are maintained below the noise standards set by local communities.
I. Animal Welfare
②
Mobis India business partners shall comply with article 23 of the Animal Protection Act if conducting experimentation on animals inevitably. ③
Mobis India business partners shall respect the five freedoms of animals determined by the World Organization for Animal Health.
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Freedom from hunger or thirst
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Freedom from discomfort
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Freedom from pain, injury or disease
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Freedom to express (most) normal behavior
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Freedom from fear and distressJ. Protection of Biodiversity and Prohibition of Deforestation
①
Mobis India business partners shall measure the effects and degree of dependence of business activities on biodiversity, and implement plans and strategies that prevent, reduce, and offset negative impacts to preserve/restore/expand the biodiversity of local society. ②
Mobis India business partners shall construct a procedure that inspects possibility of potential deforestation by business activities to protect the forest of local society, and prepare a response system against deforestation or its risk.
4. Labor/Human Rights
A. Prohibition of Child Labor
① Mobis India business partners shall not employ child labor at any stage of production, defined as: 1) Individuals aged 15 or younger
2) Individuals currently attending compulsory education
3) Individuals below the legal minimum working age
②
Mobis India business partners shall have zero tolerance of any type of child labor in all workplaces unless allowed according to child labor laws, check the legal documents such as identifications, birth certificates of employees and job applicants to confirm their ages, and take follow-up measures such as improvement/education programs after ceasing hiring when child labor is found.
③
Mobis India business partners shall not input minors on high-risk work, and there shall be measures protecting the minors from discrimination in educational opportunities due to their work.
④
Mobis India business partners shall not be provided goods and services from suppliers (sub-suppliers) that violate the child labor laws and regulations, and take appropriate actions if above matters are confirmed.
B. Prohibition of Using Forced Labor
①
Mobis India business partners shall input employees according to laws and regulations of each country where they carry on their business, and must not force any types of mandatory work against employees' will. "Forced labor" means works or services provided by workers involuntary under threats of penalties or disciplinary actions, and it includes involuntary labor of prisoners and its labor contract by penal sanctions.
②
Mobis India business partners do not use forced labor to produce the whole products or a part of them, supplie smanufactured 100% or partially by a person or corporate that is subject to the regulations on forced labor, or by breach of the regulations. "Regulations of forced labor" contains laws, enforcement ordinances, ordinances, rules or conditions (including the import prohibition of products 100% or partially manufactured by forced labor) that are frequently imposed, executed, or implemented to prevent forced labor by the United Nations (U.N.), the US (including the US Customs and Border Protection), the European Union (EU), the Republic of Korea, and other authorities.
③
Mobis India business partners conduct a risk-based due diligence against the supply chain, and the due diligence contains mapping the supply chain of the partners to find out use of forced labor, and identifying regions, suppliers, and other factors that might cause significant risk relating to the forced labor. The due diligence is updated regularly.
④
Mobis India business partners enact a Code of Conduct that states prohibition of forced labor at any stage in a process within the supply chain. Each business partners shall prepare and implement a procedure to identify countries and regions relating to all raw materials, parts, and components directly or indirectly used in manufacturing articles which are delivered to Mobis India at any stage in a process within the supply chain to create the Code of Conduct. The Code of Conduct and relevant procedures shall be composed not to be supplied raw materials and parts directly or indirectly manufactured by forced labor at any stage in a process within the supply chain.
⑤
Mobis India business partners educate their executives and employees, suppliers about the Code of Conduct and prohibition of forced labor regularly.
⑥
Mobis India business partners proceed corrective measures when identifying forced labor in the supply chain, and provide relevant information to Mobis India immediately.
⑦
Mobis India business partners require their suppliers (sub-suppliers) to apply identical Code of Conduct and related procedures, and verify that the suppliers comply with the Code of Conduct and related procedures through inspections and monitoring.
⑧
Mobis India business partners shall not require identification or visa that might limit individual activities, restrict physical/psychological actions such as violence, threat, and immurement aiming forced labour.
⑨
Mobis India business partners shall not be supplied goods and services from suppliers (sub-suppliers) that are involved in forced labor by physical/psychological restriction or claim obligation relationship, and shall call for the suppliers (sub-suppliers) to get an) identical commitment with above to their partners.
⑩
When Mobis India business partners are aware of the fact that their suppliers use forced labor during production (including products for sale directly and indirectly used the labor), they shall immediately report to Mobis India after ceasing business with applicable suppliers.
C. Discrimination and Harassment Prevention
①
Mobis India business partners shall not discriminate in recruitment, promotion, education and training of their executives and employees on grounds of sex, race, nationality, religion, disability, age, marriage, pregnancy, family status, social position, and political opinion. ②
Mobis India business partners shall not discriminate in wage and welfare of their employees.
③
Mobis India business partners do not require conditions that are unnecessary for relevant jobs when they hiring and recruiting.
④
Mobis India business partners shall prepare a policy and procedure that prevents inhumane acts including sexual harassment, physical/psychological coercion, or abusive language, and may refer to the human rights policy and the Code of Conduct of Mobis India and a Code of Conduct of Mobis India partners.
D. Compensation and Welfare
①
Mobis India business partners shall pay wage according to laws and regulations of each country where they run their business. The wage shall be paid on time, and a pay slip with understandable language for their employees shall be also provided. ②
Mobis India business partners shall make an effort to provide a pleasant working environment, and to operate a welfare system for improving quality of life.
③
Mobis India business partners shall conduct compulsory educations provided under laws and regulations of each country where they carry on their business. Moreover, they shall strive to strengthen capabilities and develop career of their employees.
E. Management of Working Hours
① Mobis India business partners shall comply with the statutory working hours of each country where they operate and manage total working hours including breaks. Weekly working hours, including overtime, shall not exceed 60 hours or statutory working hours, except in emergencies or exceptional circumstances. ②
Mobis India business partners shall sublate involuntary extended work, and provide reasonable compensation in the case of inevitable extended work.
③
Mobis India business partners shall guarantee day-off more than once a week.
F. Humane Treatment
①
Mobis India business partners shall respect employees' privacy and refrain unnecessary work orders outside working hours. ②
Mobis India business partners shall prenotify collecting personal information of employees, and ask for a voluntary agreement of them.
③
Mobis India business partners shall ban acts that cause physical/mental pain to other employees using positional superiority in the workplace or harassment that deteriorates working environment and take proper actions such as changing working place, turnover, reprimand per the aggrieved person's request.
G. Freedom of Association and Collective Bargaining
① Mobis India business partners shall respect the labor relations acts of the countries where this Code of Conduct for business partners applies. Each workplace shall uphold workers’ rights to organize and join trade unions and to freely associate with other workers for collective bargaining, peaceful assembly and demonstrations, in accordance with local regulations.
H. Ethical Recruitment
①
Mobis India business partners shall not restrict employees from identification documents (identification, passport, driving license, etc.) by storage, disuse, concealment, forfeit or other ways unless law allows. ②
Mobis India business partners shall not ask for any types of commission in the name of recruitment.
③
Mobis India business partners shall give a written notice or explain with understandable language for employees about working conditions.
5. Safety/Health
A. Construction of Safety and Health Management System
①
Mobis India business partners shall comply with safety and health-related laws and regulations of each country where they run their business, and acquire/maintain all the safety and health licensing required for the business.
②
Mobis India business partners shall operate a safety and health management system7 that consists of organization, planning, support, performance evaluation to prevent safety and health accidents resulting from the business.
B. Safety Management of Machine/Equipment/Facility
①
Mobis India business partners shall regularly inspect and evaluate stability of dangerous machine/equipment/facility within the workplace. ②
Mobis India business partners shall install and manage safety device, protective wall, and emergency device to prevent safety accidents depending on use of dangerous machine/equipment/facility within the workplace.
③
Mobis India business partners shall provide protective gear for their employees. The protective gear shall be easy to use, and maintained to make it function at a proper time.
C. Response against Emergency
①
The business partners shall establish a plan that can respond against emergency situations such as natural disaster, herd infection, fire and safety accidents. Furthermore, they shall prepare a manual that consists of report, response, follow-up measures in case of emergency. ②
Mobis India business partners shall conduct a training according to the manual and self-established plan, laws and regulations by country that they carry out their business to respond against emergency.
③
Mobis India business partners shall have escape route, exit sign, fire detector/alarm, and fire protection system, and regularly check them.
D. Safety-related Incident Management
① Mobis India business partners shall construct a system to monitor safety-related incidents. “Safety-related incidents” refer to any and all events that impact safe workplace management, including near misses, accidents, occupational illnesses and cases requiring medical treatment. ② In the event of a safety-related incident, Mobis India business partners shall make an effort to investigate the cause and to implement improvement measures.
③
When industrial disasters or serious diseases occur, Mobis India business partners shall make an effort to investigate its root cause and prepare corrective measures.
E. Diagnosis of Safety
①
The business partners shall conduct regular evaluation of safety risk for the workplace aiming to check that employees are exposed to accidents and harmful factors. The result of the evaluation shall be notified to executives and employees, and machine/equipment/facility shall be improved according to the result. ②
Mobis India business partners shall provide information on accident risk and harmful factors of the workplace to employees based on the evaluation of safety risk. The information shall be prepared with understandable language, and placed in accessible places.
③
Mobis India business partners shall not input pregnant women and minors to high-risk work in terms of safety and health, and strive to create a proper working environment for disabled person, immigrant, and other disadvantaged.
F. Health Care
①
Mobis India business partners may provide staff lounges, restrooms, and cafeterias, and shall put an effort to keep the facilities clean if they provide them. ②
The business partners may provide a dormitory in this case, there should be safety sign, lights, and heating and cooling system. There shall be a proper device to control visitor access in a dormitory.
③
Mobis India business partners shall conduct regular health checkup and special checkup for their executives and employees according to health promotion laws of each country where they run their business. Moreover, there shall be measures that change work spaces/jobs and reduce working hours as a result of the checkup.
G. Safety and Health of Contractor
①
Mobis India business partners shall manage safety and health of contractor when the contractor performs a job for profits of the company.
H. Prohibition of Hazardous Work for Vulnerable Workers
① Mobis India business partners shall not assign overtime, night shifts, or hazardous tasks to young workers, as well as any work that may pose health or safety risks to women who are pregnant or have recently given birth.
6. Management System
A. Code of Conduct Establishment & Corporate Statement Disclosure
① Mobis India business partners shall establish and disclose a Code of conduct necessary for compliance management and ESG practices. ②
Mobis India business partners shall internally·externally spread this Code of Conduct or will to fulfill sustainable management which is corresponding to the code.
③
Mobis India business partners shall share this Code of Conduct or will to fulfill sustainable management which is corresponding to the code through new year address, internal guidance, and bulletin board. It is recommended to use website, business report, promotional materials to open to the public.
B. Appointment of Manager
①
Mobis India business partners shall appoint a person who is charge of the compliance and sustainable work. ②
Mobis India business partners shall assign a manager who supervises planning the compliance and sustainable management activities and its execution.
C. Inspection of Risk
①
Mobis India business partners shall strive to identify risks that might occur in ethic, environmental, labor/human rights, safety/health, and other areas such as compliance while they operate their business.②
When Mobis India business partners identify significant risk, they shall prepare and implement a plan to mitigate the risk.
D. Education and Communication
①
Mobis India business partners shall educate their executives and employees about the code and relevant laws/regulations. ②
Mobis India business partners shall share a promotion plan of the Code of Conduct and its execution with their executives and employees.
E. Management of Information
①
Mobis India business partners shall record and manage risks, information and the current status of ethic, environmental, labor/human rights, safety/health, compliance, and other areas. ②
Mobis India business partners shall make an effort to disclose information limpidly when laws and regulations of each country, industrial associations, and major clients that signed the contract require the information unless laws prohibit.
F. Operation of Grievance Settlement System
①
Mobis India business partners shall operate a grievance settlement system that can report a breach of laws and regulations in ethic, environmental, labor/human rights, safety/health, compliance and other areas, or a violation of individual's rights and interests relating to the areas. ②
Mobis India business partners shall keep personal data of whistle-blowers and details of report confidential, and protect the whistle-blowers against illogical measures such as dismissal, threat, revenge, and ridicule. Status of the whistle-blowers shall be guaranteed.
G. Preparation of Relief Plan
①
When there is a victim caused from negative impact of sustainable supply chain by business activities, Mobis India business partners shall prepare a relief plan by considering scale and importance of damage. ②
Mobis India business partners shall discuss with victims and representatives when deciding a relief plan, and prepare the plan in accordance with international standards.
H. Management of Suppliers (sub-supplier)
① Mobis India business partners shall encourage all supply chain participants, including suppliers and other sub-business partners, involved in planning, designing, selling and manufacturing products and services to manage ethics, environment, labor/human rights, safety/health and other compliance elements, and shall implement an effective process to ensure that major business partners comply with Mobis India’s Supply Chain Code of Conduct.
②
Mobis India business partners shall make an effort to recommend or induce improvement to companies that participate in the supply chain such as their suppliers (sub-cooperative partners) when the fact that the companies violate laws and regulations in ethic, environmental, labor/human rights, safety/health, and other areas (including compliance) is identified.
I. Compliance with the Code of Conduct
①
When there is a written inspection or on site visit by a third party assigned by Mobis India to check the compliance of Mobis India business partners without violating related laws and regulations, the partners shall provide relevant information on compliance with the Code of Conduct to the third party. ②
Mobis India business partners shall prepare·manage proper documents that can prove their compliance with the Code of Conduct, and the documents shall be prepared based on actual facts of the business.
③
Mobis India business partners shall strive to establish and implement a plan that improves faults and violations as a result of the inspections and on-site visits in a timely manner.
7. Due Diligence of Supply Chain
①
Mobis India business partners shall identify and evaluate risks on sustainability that might generate in the supply chain within the related laws and regulations, and monitor the process of risk mitigation. ②
Mobis India business partners shall prepare a six-stage procedure with reference to OECD Due Diligence Guidance for Responsible Business Conduct.
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Establish a basic policy to implement responsible management and embrace the policy into a management system of the company
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Identify negative impacts (actual·potential risk) on stakeholders during business process and evaluate them
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Formulate a plan to cease, prevent, mitigate the negative impacts and implement the plan
•
Monitor the progress of execution for measures that identify, prevent, reduce the negative impacts and its result
•
Share and communicate information on policies, procedures, and actions relating to due diligence with the outside
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Provide proper means to deal with negative impacts or cooperate with others who provide the proper means
1. It refers to the minerals, such as tin, tantalum, tungsten, and gold, unethically produced in and distributed from conflict regions in Africa (10 countries including DR Congo, the Central African Republic, South Sudan, Uganda, Burundi, Tanzania, Zambia, Angola, etc.) through human rights abuses or environmental destruction.
2. It refers to the minerals produced in a way that does not finance disputes, respects human rights and the environment, and fulfills social responsibilities (e.g. cobalt).
3. Listed companies shall disclose the use of conflict minerals on their products according to an enforcement ordinance of the U.S. Securities and Exchange Commission in 2012. In 2015, the European Parliament required importers of minerals to report the countries of origin and results of inspecting issues to the applicable authorities of each country.
4. ISO14001 Standard, etc. (ISO14001 Standard is an international standard for the Environmental Management System (EMS) that is enacted by International Organization for Standardization (ISO) to induce a continuous environmental performance throughout the whole enterprise activities, and it can be approved by a third party if environmental management is conducted in accordance with the standard)
5. Greenhouse gas emissions are classified into Scope 1, Scope 2, and Scope 3 under the internationally accepted GHG Protocol. Scope 1 refers to direct emissions from facilities and equipment directly owned or controlled by the company (e.g., fuel combustion and process gases). Scope 2 refers to indirect emissions resulting from the use of the purchased energy such as electricity, heat, and steam. Scope 3 refers to other indirect emissions occurring across the company’s entire value chain, including the supply chain and the use and disposal of products, which represents the broadest category of emissions.
6. Scope 3 emission sources are divided into fifteen categories, covering the entire process from the procurement of raw materials and components to the use and disposal of products. Among these, Category 1 (purchased goods & services) refers to the greenhouse gas emissions generated from the production of raw materials, components and outsourced services purchased by the company. This category is the largest contributor within Scope 3 for most manufacturing industries. The remaining Scope 3 categories are classified into upstream and downstream stages. Upstream includes capital goods, fuel supply, transportation, waste, business trip and commuting, while downstream includes emission occurring after value chain stages, such as product distribution, process, use, disposal, rental assets, franchises and investments.
7. ISO45001, KOSHA18001 Standard, ec (Safety and health management principle is created by autonomous policy of entrepreneur, and it enables to improve gradually a safety and health system by planning, execution, inspection, and evaluation. For examples, there are ISO45001 created by International Standard Organization (ISO), and KOSHA18001 developed by Korea Occupational Safety and Health Agency as a Korean model.
